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Presented at Public Meeting

April 19, 2013

Chevron Richmond Refinery

August 6, 2012 Fire

CSB Interim Report Findings and

Recommendations

• Received inquiry from Contra Costa County concerning

possible air monitoring support;

• OSC arrived at Chevron EOC to provide technical support

as needed.

• EPPS inspector onsite to begin investigation on 08/08/12.

• In collaboration with CSB, CalOSHA, County CUPA, City

and BAAQMD.

• EPA investigation conducted with support from HQ and

other Regions and covered processes other than 4Crude.

• EPA’s expanded investigation complete by June 30th.

4

US EPA Region IX’s

Response

Th

• Failure caused by sulfidation corrosion in low-silicon carbon steel.

Inherently Safer Materials of Construction

Low-Silicon Carbon

Steel >.1% Silicon

Carbon Steel 9-Chrome Stainless Steel

INHERENTLY SAFER

Thinning resulting from 15 years of operation (Estimated)

90 % Wall Loss 65% Wall Loss 9% Wall Loss < 1% Wall Loss

Chevron 4-sidecut

Material of Construction

Low-Silicon 4-Sidecut Component Not Monitored Measurement

Location

Weld High-Silicon

Elbow Component

Low-Silicon

Pipe Component

Low-Silicon 4-Sidecut Component Not Monitored

~2002

#3 CML

Many Chevron Recommendations to Inspect or Upgrade 4-Sidecut

2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Pipe Ruptures

Recommendations to 100 Percent Inspect 4-Sidecut

Recommendations to Upgrade Metallurgy of 4-Sidecut

Inspection of piping TML/CML location #3

Process Feed Changes

• These reviews:

– Analyze all process equipment failure mechanisms including:

• Corrosion

• Cracking

– Identify needed safeguards to control or eliminate hazard.

• Not required by regulations or by Chevron standards

– Review findings could have caused Process Hazard Analysis

(PHA) team to recommend 4-sidecut line replacement.

Damage Mechanism Hazard Reviews CSB’s Findings

• CSB recommendation:

⁻ Chevron should conduct damage mechanism reviews at

all their U.S. facilities.

⁻ State, County and local agencies should require this

review at all refineries as part of the

Process Hazard Analysis.

Damage Mechanism Hazard Reviews

Inherently Safer Systems (ISS) analysis is required in

Contra Costa County and City of Richmond’s Regulations

as part of PHAs and new construction.

The ISS analysis in PHA at Chevron was a “Check-the-

Box” activity not a detailed process-specific analysis.

Regulation only requires analysis be

considered “…shall consider the use

of inherently safer systems…”

Inherently Safer Systems Analysis CSB’s Findings

CSB’s Recommendations:

State, County and local agencies should require ISS

analysis at every opportunity in the process, including all parts

of the prevention program which generate recommendations.

Inherently Safer Systems Analysis

• Use of LOPA to achieve ALARP:

– LOPA can be used to reduce risk to “As Low

As Reasonably Practicable” or ALARP.

– Risk reduction continues to the practical limit.

• LOPA can confirm:

– Safeguards are adequate.

– Inherently safer design is optimally in place.

• Chevron is a member of CCPS and peer-reviewed

the LOPA publication.

Adequate Hazard Analysis Methodologies Drive Risk to As Low As Reasonably Practicable

• CBS Recommendation:

− Chevron should report leading and lagging indicators to

federal, state and local agencies for all California refineries.

− State and local agencies should require facilities to

report leading and lagging indicators studies and

LOPA information.

Adequate Hazard Analysis Methodologies Drive Risk to As Low As Reasonably Practicable

• Program will improve public accountability and process safety

performance.

• Sharing of data and operational coordination will help

regulators prevent major incidents.

• Regulators have cited the need for

greater multi-agency cooperation.

Multi-Agency Regulatory Approach Needed

• CBS Recommendation:

• State should develop and implement a multi-agency

program for regulation of PSM at refineries,

including information sharing and coordination

of compliance monitoring activities.

EPA should participate as well.

Multi-Agency Regulatory Approach Needed

Transparency Drives Process Safety • Transparency is the public disclosure of process safety

information.

• Minimal transparency exists between refineries, regulators, and

the public.

• Transparency allows local officials, regulators, the workforce, and

the public to work with industry to prevent major incidents.

• NOTE: Current laws, such as

those implemented by the

US Department of Homeland

Security, prohibit public disclosure

of some information.

• Failure caused by sulfidation corrosion

in low-silicon carbon steel.

• Chevron failed to shut down unit when

leak was found.

• Chevron never replaced 4-sidecut

despite many recommendations.

• Chevron Process Hazard Analysis

(PHA) process failed to identify

sulfidation corrosion hazard.

Many Factors Contributed to Incident

• Regulations did not require a damage

mechanism hazard review.

• Regulations did not require evaluation of

safeguard effectiveness.

• Regulations did not require rigorous

Inherently Safer System implementation.

• Multi-agency cooperation and

transparency needed in California

Many Factors Contributed to Incident

Questions? CSB Interim Report and additional resources

available at

http://CSB.gov